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                        Federal Communications Commission           DA 18-1051 

                                  Before the 
                        Federal Communications Commission 
                             Washington, DC 20554 
 
In the Matter of                       )         
                                       )         
Gable Signs & Graphics, Inc.           )        File No.:  EB-SED-17-00024678 
                                       )        Acct. No.:  201832100033 
                                       )        FRN:  0027874254 
                                        
                                   ORDER 
 
Adopted:  November 27, 2018                            Released:  November 27, 2018 
 
By the Deputy Chief, Enforcement Bureau: 
 
      1.    The Enforcement Bureau (Bureau) of the Federal Communications Commission has 
entered into a Consent Decree to resolve its investigation into whether Gable Signs & Graphics, Inc. 
(Gable) violated the Commission s rules by marketing light-emitting diode (LED) signs used in digital 
billboards and other commercial and industrial applications without the required equipment authorization, 
labeling, and user manual disclosures, and by failing to produce certain required test records.  These rules 
ensure that radio-frequency devices marketed in the United States do not interfere with authorized 
communications, thereby maintaining network integrity and security and protecting consumers.  To settle 
this matter, Gable admits that it violated the Commission s rules, will implement a compliance plan, and 
will pay a $50,000 civil penalty.  
      2.    After reviewing the terms of the Consent Decree and evaluating the facts before us, we 
find that the public interest would be served by adopting the Consent Decree and terminating the 
referenced investigation regarding Gable s compliance with the equipment authorization, labeling, user 
manual disclosure, and record retention rules in effect at the time of the violations, Section 302(b) of the 
Communications Act of 1934, as amended (Act),1 and Sections 2.803, 2.955, 15.19, 15.21, 15.101, and 
15.105 of the Commission s rules.2 
      3.    In the absence of material new evidence relating to this matter, we do not set for hearing 
the question of Gable s basic qualifications to hold or obtain any Commission license or authorization.3 
      4.    Accordingly, IT IS ORDERED that, pursuant to Section 4(i) of the Act,4 and the 
authority delegated by Sections 0.111 and 0.311 of the Commission s rules,5 the attached Consent Decree 
IS ADOPTED and its terms incorporated by reference. 
      5.    IT IS FURTHER ORDERED that the above-captioned matter IS TERMINATED. 


                                                     
1 47 U.S.C.  302a(b). 
2 47 CFR  2.803, 2.955, 15.19, 15.21, 15.101, 15.105 (2017).  Some of the rules in effect at the time the violations 
occurred were subsequently amended.  The new rules became effective on November 2, 2017.  See Amendment of 
Parts 0, 1, 2, 15, and 18 of the Commission s Rules Regarding Authorization of Radiofrequency Equipment, Report 
and Order, 32 FCC Rcd 8746 (2017). 
3 See 47 CFR  1.93(b). 
4 47 U.S.C.  154(i). 
5 47 CFR  0.111, 0.311. 

 
                        Federal Communications Commission           DA 18-1051 
 

      6.    IT IS FURTHER ORDERED that a copy of this Order and Consent Decree shall be 
sent by first class mail and certified mail, return receipt requested, to Paul Sweeney, Esq., Yumkas, 
Vidmar, Sweeney & Mulrenin, LLC, 10211 Wincopin Circle, Suite 500, Columbia, Maryland 21044, and 
to Paul P. Gable, President, Gable Signs & Graphics, Inc., 7440 Fort Smallwood Road, Baltimore, 
Maryland 21226. 
       

                              FEDERAL COMMUNICATIONS COMMISSION 
 
 
                               
 
                              Christopher L. Killion 
                              Deputy Chief 
                              Enforcement Bureau


                                      2 
 
                        Federal Communications Commission           DA 18-1051 

                                  Before the 
                        Federal Communications Commission 
                             Washington, D.C. 20554 
 
 
In the Matter of                       )     
                                       )     
Gable Signs & Graphics, Inc.           )       File No.:  EB-SED-17-00024678 
                                       )       Acct. No.:  201832100033 
                                       )       FRN:  0027874254   
                                       ) 
                                        
                              CONSENT DECREE 
 
      1.    The Enforcement Bureau of the Federal Communications Commission and Gable Signs 
& Graphics, Inc. (Gable), by their authorized representatives, hereby enter into this Consent Decree for 
the purpose of terminating the Enforcement Bureau s investigation into whether Gable violated Section 
302(b) of the Communications Act of 1934, as amended,6 and Sections 2.803, 2.955, 15.19, 15.21, 
15.101, and 15.105 of the Commission s rules.7  
I.    DEFINITIONS 
      2.    For the purposes of this Consent Decree, the following definitions shall apply: 
            (a)  Act  means the Communications Act of 1934, as amended.8 
            (b)  Adopting Order  means an order of the Bureau adopting the terms of this Consent 
               Decree without change, addition, deletion, or modification. 
            (c)  Bureau  means the Enforcement Bureau of the Federal Communications 
               Commission. 
            (d)  Commission  and  FCC  mean the Federal Communications Commission and all 
               of its bureaus and offices. 
            (e)  Communications Laws  means collectively, the Act, the Rules, and the published 
               and promulgated orders and decisions of the Commission to which Gable is subject 
               by virtue of its business activities, including but not limited to the Equipment 
               Marketing Rules. 
            (f)  Compliance Plan  means the compliance obligations, program, and procedures 
               described in this Consent Decree at paragraph 13. 
            (g)  Covered Employees  means all employees and agents of Gable who perform, or 
               supervise, oversee, or manage the performance of, duties that relate to Gable s 
               responsibilities under the Communications Laws, including the Equipment 
               Marketing Rules. 

                                                     
6 47 U.S.C.  302a(b). 
7 47 CFR  2.803, 2.955, 15.19, 15.21, 15.101, 15.105.  Some of the rules in effect at the time the violations 
occurred were subsequently amended and became effective on November 2, 2017.  See Amendment of Parts 0, 1, 2, 
15, and 18 of the Commission s Rules Regarding Authorization of Radiofrequency Equipment, Report and Order, 32 
FCC Rcd 8746 (July 2017) (Equipment Authorization Order).  This settlement resolves the rule violations listed in 
para. 1 of this Consent Decree and sets forth obligations for compliance with the current rules. 
8 47 U.S.C.  151 et seq. 

 
                        Federal Communications Commission           DA 18-1051 

            (h)  Effective Date  means the date by which both the Bureau and Gable have signed 
               the Consent Decree. 
            (i)  Equipment Marketing Rules  means Section 302(b) of the Act;9 Sections 2.803, 
               2.938 or 2.955, 2.1077, 15.19, 15.21, 15.101, and 15.105 of the Commission s 
               rules;10 and other provisions of the Act, the Rules, and Commission orders related to 
               the authorization of radio frequency devices and the marketing of such devices. 
            (j)   Gable  or  Company  means Gable Signs & Graphics, Inc. and its affiliates, 
               subsidiaries, predecessors-in-interest, and successors-in-interest. 
            (k)  Investigation  means the investigation commenced by the Bureau in File No. EB-
               SED-17-00024678 regarding whether Gable violated the Equipment Marketing 
               Rules.11 
            (l)  Operating Procedures  means the standard internal operating procedures and 
               compliance policies established by Gable to implement the Compliance Plan. 
            (m)  Parties  means Gable and the Bureau, each of which is a  Party.  
            (n)  Rules  means the Commission s regulations found in Title 47 of the Code of 
               Federal Regulations. 
II.   BACKGROUND 
      3.    Section 302 of the Act authorizes the Commission to promulgate reasonable regulations 
to minimize harmful interference by equipment that emits radio frequency energy.12  Specifically, 
Section 302(b) of the Act provides that  [n]o person shall manufacture, import, sell, offer for sale, or ship 
devices or home electronic equipment and systems, or use devices, which fail to comply with regulations 
promulgated pursuant to this section. 13  The purpose of Section 302 of the Act is to ensure that radio 
transmitters and other electronic devices meet certain standards to control interference before they reach 
the market. 
      4.    The Commission carries out its responsibilities under Section 302 of the Act in two ways.  
First, the Commission establishes technical requirements for transmitters and other equipment to 
minimize their potential for causing interference to authorized radio services.  Second, the Commission 
administers an equipment authorization program to ensure that equipment reaching the market in the 
United States complies with the technical and administrative requirements set forth in the Rules.  The 
equipment authorization program requires, among other things, that radio frequency devices must be 
tested for compliance with the applicable technical requirements prior to marketing.14  In that regard, 
Section 2.803(b) of the Rules prohibits the marketing of radio frequency devices unless the device has 

                                                     
9 Id.  302a(b). 
10 47 CFR  2.803, 2.938, 2.1077, 15.19, 15.101 (2018); id.  2.803, 2.955, 15.19, 15.21, 15.101, 15.105 (2017).   
11 See, e.g., Revised Letter of Inquiry from Aspasia A. Paroutsas, Chief, Spectrum Enforcement Division, FCC 
Enforcement Bureau, to Joe Tremble, President, Chief Executive Officer, Gable Signs & Graphics, Inc. (July 21, 
2017) (LOI); Supplemental Letter of Inquiry from Aspasia A. Paroutsas, Chief, Spectrum Enforcement Division, 
FCC Enforcement Bureau, to G. Henry Caple, Vice President of Finance, Gable Signs & Graphics, Inc. (Sept. 22, 
2017) (both on file in EB-SED-17-00024678). 
12 47 U.S.C.  302a. 
13 Id.  302a(b). 
14 The term  marketing  is defined in the Rules and includes the  sale or lease, or offering for sale or lease, 
including advertising for sale or lease, or importation, shipment, or distribution for the purpose of selling or leasing 
or offering for sale or lease.   47 CFR  2.803(a). 

                                      2 
                        Federal Communications Commission           DA 18-1051 

first been properly authorized, identified, and labeled in accordance with the Rules, with limited 
exceptions.15 
      5.    Gable is a Maryland-based corporation that fabricates, imports, and sells fully assembled 
light-emitting diode (LED) display signs.16  On July 12, 2017, after reviewing a complaint, the Bureau s 
Spectrum Enforcement Division issued a Letter of Inquiry (LOI) to Gable, directing it to submit a sworn 
written response to a series of questions relating to its marketing of LED signs in the United States.17  The 
investigation revealed that Gable violated the Equipment Marketing Rules by marketing LED signs18 
without the required equipment authorization, labeling, and user manual disclosures,19 and by failing to 
produce certain required test records.20  After receiving the LOI, Gable began the process of bringing its 
LED signs into compliance with the Commission s Equipment Marketing Rules by obtaining 
authorizations for models that had not been properly authorized, and by marketing compliant equipment 
with the proper labels and user manual disclosures.21  The Company achieved compliance with the 
relevant Equipment Marketing Rules in January 2018 for the LED signs at issue.22 
      6.    The Bureau and Gable negotiated the following terms and conditions of settlement and 
hereby enter into this Consent Decree as provided herein. 
III.  TERMS OF AGREEMENT 
      7.    Adopting Order.  The provisions of this Consent Decree shall be incorporated by the 
Bureau in an Adopting Order. 
      8.    Jurisdiction.  Gable agrees that the Bureau has jurisdiction over it and the matters 
contained in this Consent Decree and has the authority to enter into and adopt this Consent Decree. 
      9.    Effective Date; Violations.  The Parties agree that this Consent Decree shall become 
effective on the Effective Date as defined herein.  As of the Effective Date, the Parties agree that this 
Consent Decree shall have the same force and effect as any other order of the Commission.   
      10.   Termination of Investigation.  In express reliance on the covenants and representations 
in this Consent Decree and to avoid further expenditure of public resources, the Bureau agrees to 
terminate the Investigation.  In consideration for the termination of the Investigation, Gable agrees to the 
terms, conditions, and procedures contained herein.  The Bureau further agrees that, in the absence of new 
material evidence, it will not use the facts developed in the Investigation through the Effective Date, or 
the existence of this Consent Decree, to institute, on its own motion, any new proceeding, formal or 
informal, or take any action on its own motion against Gable concerning the matters that were the subject 
of the Investigation.  The Bureau also agrees that, in the absence of new material evidence, it will not use 
the facts developed in the Investigation through the Effective Date, or the existence of this Consent 
                                                     
15 See id.  2.803(b), (c). 
16 See, e.g., Letter of Inquiry Response from G. Henry Caple, Vice President of Finance, Gable Signs & Graphics, 
Inc., to Christopher Sova, Deputy Chief, Investigations and Hearings Division, FCC Enforcement Bureau (Apr. 13, 
2018) (LOI Response) (on file in EB-SED-17-00024678).  
17 See supra note 6.   
18 Such signs constitute  unintentional radiators  within the meaning of Section 15.3(z) of the Commission s rules.  
47 CFR  15.3(z). 
19 See, e.g., LOI Response; E-mail from Hank Caple, Vice President-Finance, Gable Signs & Graphics, Inc. to Leslie 
Barnes, Assistant Chief, Spectrum Enforcement Division, Enforcement Bureau, FCC (June 1, 2018, 19:00 EDT) 
(Supplemental LOI Response) (both on file in EB-SED-17-00024678).   
20 47 CFR  2.955.  
21 See Supplemental LOI Response at 5. 
22 Cf. 47 CFR  2.803, 2.955, 15.19, 15.21, 15.101, 15.105. 

                                      3 
                        Federal Communications Commission           DA 18-1051 

Decree, to institute on its own motion any proceeding, formal or informal, or to set for hearing the 
question of Gable s basic qualifications to be a Commission licensee or hold Commission licenses or 
authorizations.23 
      11.   Admission of Liability.  Gable admits for the purpose of this Consent Decree and for 
Commission civil enforcement purposes, and in express reliance on the provisions of paragraph 10 herein, 
that its actions described in paragraph 5, herein, violated the Equipment Marketing Rules in effect during 
the Investigation. 
      12.   Compliance Officer.  Within thirty (30) calendar days after the Effective Date, Gable 
shall designate a senior corporate manager with the requisite corporate and organizational authority to 
serve as a Compliance Officer and to discharge the duties set forth below.  The person designated as the 
Compliance Officer shall be responsible for developing, implementing, and administering the Compliance 
Plan and ensuring that Gable complies with the terms and conditions of the Compliance Plan and this 
Consent Decree.  In addition to the general knowledge of the Communications Laws necessary to 
discharge his or her duties under this Consent Decree, the Compliance Officer shall have specific 
knowledge of the Equipment Marketing Rules prior to assuming his or her duties. 
      13.   Compliance Plan.  For purposes of settling the matters set forth herein, Gable agrees that 
it shall, within sixty (60) calendar days after the Effective Date, develop and implement a Compliance 
Plan designed to ensure future compliance with the Communications Laws and with the terms and 
conditions of this Consent Decree.  With respect to the Equipment Marketing Rules, Gable will 
implement, at a minimum, the following procedures: 
            (a) Operating Procedures.  Within thirty (30) calendar days after the Effective Date, 
               Gable shall establish Operating Procedures that all Covered Employees must follow 
               to help ensure Gable s compliance with the Equipment Marketing Rules.  Gable s 
               Operating Procedures shall include internal procedures and policies specifically 
               designed to ensure that all radio frequency devices to be marketed by Gable are 
               properly authorized and compliant with the applicable technical and administrative 
               standards and requirements prior to the initiation of marketing.24  Additionally, 
               Gable will establish a procedure for retaining documentation supporting device 
               compliance prior to the initiation of marketing.25  Gable shall also develop a 
               Compliance Checklist that describes the steps that a Covered Employee must follow 
               to ensure compliance with the Equipment Marketing Rules. 
            (b) Compliance Manual.  Within sixty (60) calendar days after the Effective Date, the 
               Compliance Officer shall develop and distribute a Compliance Manual to all 
               Covered Employees.  The Compliance Manual shall explain the Equipment 
               Marketing Rules and set forth the Operating Procedures that Covered Employees 
               shall follow to help ensure Gable s compliance with the Equipment Marketing 
               Rules.  Gable shall periodically review and revise the Compliance Manual as 
               necessary to ensure that the information set forth therein remains current and 
               accurate.  Gable shall distribute any revisions to the Compliance Manual promptly 
               to all Covered Employees. 
            (c) Compliance Training Program.  Gable shall establish and implement a 
               Compliance Training Program in compliance with the Equipment Marketing Rules 
               and the Operating Procedures.  As part of the Compliance Training Program, 
                                                     
23 See 47 CFR  1.93(b). 
24 See supra note 9 and accompanying text. 
25 See 47 CFR  2.938, 2.945 (2018); id.  2.955 (2017); see also Equipment Authorization Order, 32 FCC Rcd at 
8786-88, Appx. A.  

                                      4 
                        Federal Communications Commission           DA 18-1051 

               Covered Employees shall be advised of Gable s obligation to report any 
               noncompliance with the Equipment Marketing Rules under paragraph 14 of this 
               Consent Decree and shall be instructed on how to disclose noncompliance to the 
               Compliance Officer.  All Covered Employees shall be trained pursuant to the 
               Compliance Training Program within sixty (60) calendar days after the Effective 
               Date, except that any person who becomes a Covered Employee at any time after the 
               initial Compliance Training Program shall be trained within thirty (30) calendar 
               days after the date such person becomes a Covered Employee.  Gable shall repeat 
               compliance training on an annual basis, and shall periodically review and revise the 
               Compliance Training Program as necessary to ensure that it remains current and 
               complete and to enhance its effectiveness. 
      14.   Reporting Noncompliance.  Gable shall report any noncompliance with the Equipment 
Marketing Rules and with the terms and conditions of this Consent Decree within fifteen (15) calendar 
days after discovery of such noncompliance.  Such reports shall include a detailed explanation of: (i) each 
instance of noncompliance; (ii) the steps that Gable has taken or will take to remedy such noncompliance; 
(iii) the schedule on which such remedial actions will be taken; and (iv) the steps that Gable has taken or 
will take to prevent the recurrence of any such noncompliance.  All reports of noncompliance shall be 
submitted to Chief, Spectrum Enforcement Division, Enforcement Bureau, Federal Communications 
Commission, 445 12th Street, SW, Rm. 3-C366, Washington, DC 20554, with a copy submitted 
electronically to Paul.Noone@fcc.gov and EB-SED-Response@fcc.gov. 
      15.   Compliance Reports.  Gable shall file compliance reports with the Commission ninety 
(90) calendar days after the Effective Date, twelve (12) months after the Effective Date, twenty-four (24) 
months after the Effective Date, and thirty-six (36) months after the Effective Date. 
            (a) Each Compliance Report shall include a detailed description of Gable s efforts 
               during the relevant period to comply with the terms and conditions of this Consent 
               Decree and the Equipment Marketing Rules.  In addition, each Compliance Report 
               shall include a certification by the Compliance Officer, as an agent of and on behalf 
               of Gable, stating that the Compliance Officer has personal knowledge that Gable:  
               (i) has established and implemented the Compliance Plan; (ii) has utilized the 
               Operating Procedures since the implementation of the Compliance Plan; and (iii) is 
               not aware of any instances of noncompliance with the terms and conditions of this 
               Consent Decree, including the reporting obligations set forth in paragraph 14 of this 
               Consent Decree. 
            (b) The Compliance Officer s certification shall be accompanied by a statement 
               explaining the basis for such certification and shall comply with Section 1.16 of the 
               Rules and be subscribed to as true under penalty of perjury in substantially the form 
               set forth therein.26 
            (c) If the Compliance Officer cannot provide the requisite certification, the Compliance 
               Officer, as an agent of and on behalf of Gable, shall provide the Commission with a 
               detailed explanation of the reason(s) why and describe fully:  (i) each instance of 
               noncompliance; (ii) the steps that Gable has taken or will take to remedy such 
               noncompliance, including the schedule on which proposed remedial actions will be 
               taken; and (iii) the steps that Gable has taken or will take to prevent the recurrence 
               of any such noncompliance, including the schedule on which such preventive action 
               will be taken. 

                                                     
26 47 CFR  1.16. 

                                      5 
                        Federal Communications Commission           DA 18-1051 

           (d) All Compliance Reports shall be submitted to Chief, Spectrum Enforcement 
               Division, Enforcement Bureau, Federal Communications Commission, 445 12th 
               Street, SW, Rm. 3-C366, Washington, DC 20554, with a copy submitted 
               electronically to Paul.Noone@fcc.gov and EB-SED-Response@fcc.gov. 
      16.   Termination Date.  Unless stated otherwise, the requirements set forth in paragraphs 12 
through 15 of this Consent Decree shall expire thirty-six (36) months after the Effective Date.   
      17.   Civil Penalty.  Gable will pay a civil penalty to the United States Treasury in the amount 
of fifty thousand dollars ($50,000).  Such payment shall be made in twelve installments (each, an 
Installment Payment). 
      "   The first Installment Payment in the amount of four thousand one hundred seventy-four 
         dollars ($4,174) is due within thirty (30) calendar days of the Effective Date. 
      "   The second Installment Payment in the amount of four thousand one hundred sixty-six dollars 
         ($4,166) is due within one hundred and twenty (120) calendar days of the Effective Date. 
      "   The third Installment Payment in the amount of four thousand one hundred sixty-six dollars 
         ($4,166) is due within two hundred and ten (210) calendar days of the Effective Date. 
      "   The fourth Installment Payment in the amount of four thousand one hundred sixty-six dollars 
         ($4,166) is due within three hundred (300) calendar days of the Effective Date. 
      "   Thereafter, each of the eight remaining Installment Payments in the amount of four thousand 
         one hundred sixty-six dollars ($4,166) is due within ninety (90) calendar days of the 
         preceding payment. 
      Gable acknowledges and agrees that upon execution of this Consent Decree, the civil penalty and 
each Installment Payment shall become a  Claim  or  Debt  as defined in 31 U.S.C.  3701(b)(1).27  
Upon an Event of Default (as defined below), all procedures for collection as permitted by law may, at the 
Commission s discretion, be initiated.  Gable shall send electronic notification of payment to Paul Noone 
at Paul.Noone@fcc.gov and to SED at EB-SED-Response@fcc.gov on the date each payment is made.  
The payment must be made by check or similar instrument, wire transfer, or credit card, and must include 
the Account Number and FRN referenced above.  Regardless of the form of payment, a completed FCC 
Form 159 (Remittance Advice) must be submitted.28  When completing the FCC Form 159, enter the 
Account Number in block number 23A (call sign/other ID) and enter the letters  FORF  in block number 
24A (payment type code).  Below are additional instructions that should be followed based on the form of 
payment selected: 
      "   Payment by check or money order must be made payable to the order of the Federal 
         Communications Commission.  Such payments (along with the completed Form 159) must be 
         mailed to Federal Communications Commission, P.O. Box 979088, St. Louis, MO 63197-
         9000, or sent via overnight mail to U.S. Bank   Government Lockbox #979088, 
         SL-MO-C2-GL, 1005 Convention Plaza, St. Louis, MO 63101. 
      "   Payment by wire transfer must be made to ABA Number 021030004, receiving bank 
         TREAS/NYC, and Account Number 27000001.  To complete the wire transfer and ensure 
         appropriate crediting of the wired funds, a completed Form 159 must be faxed to U.S. Bank 
         at (314) 418-4232 on the same business day the wire transfer is initiated. 

                                                     
27 Debt Collection Improvement Act of 1996, Pub. L. No. 104-134, 110 Stat. 1321, 1358 (Apr. 26, 1996). 
28 An FCC Form 159 and detailed instructions for completing the form may be obtained at 
http://www.fcc.gov/Forms/Form159/159.pdf. 

                                      6 
                        Federal Communications Commission           DA 18-1051 

      "   Payment by credit card must be made by providing the required credit card information on 
         FCC Form 159 and signing and dating the Form 159 to authorize the credit card payment.  
         The completed Form 159 must then be mailed to Federal Communications Commission, P.O. 
         Box 979088, St. Louis, MO 63197-9000, or sent via overnight mail to U.S. Bank   
         Government Lockbox #979088, SL-MO-C2-GL, 1005 Convention Plaza, St. Louis, MO 
         63101. 
      Questions regarding payment procedures should be addressed to the Financial Operations Group 
Help Desk by phone, 1-877-480-3201, or by e-mail, ARINQUIRIES@fcc.gov.  
      18.   Event of Default.  Gable agrees that an Event of Default shall occur upon the failure by 
Gable to pay the full amount of any Installment Payment on or before the due date specified in this 
Consent Decree. 
      19.   Interest, Charges for Collection, and Acceleration of Maturity Date.  After an Event 
of Default has occurred under this Consent Decree, the then unpaid amount of the civil penalty shall 
accrue interest, computed using the U.S. Prime Rate in effect on the date of the Event of Default plus 4.75 
percent, from the date of the Event of Default until payment in full.  Upon an Event of Default, the then 
unpaid amount of the civil penalty, together with interest, any penalties permitted and/or required by the 
law, including but not limited to 31 U.S.C.  3717 and administrative charges, plus the costs of collection, 
litigation, and attorneys  fees, shall become immediately due and payable, without notice, presentment, 
demand, protest, or notice of protest of any kind, all of which are waived by Gable. 
      20.   Waivers.  As of the Effective Date, Gable waives any and all rights it may have to seek 
administrative or judicial reconsideration, review, appeal or stay, or to otherwise challenge or contest the 
validity of this Consent Decree and the Adopting Order.  Gable shall retain the right to challenge 
Commission interpretation of the Consent Decree or any terms contained herein.  If either Party (or the 
United States on behalf of the Commission) brings a judicial action to enforce the terms of the Consent 
Decree or the Adopting Order, neither Gable nor the Commission shall contest the validity of the Consent 
Decree or the Adopting Order, and Gable shall waive any statutory right to a trial de novo.  Gable hereby 
agrees to waive any claims it may otherwise have under the Equal Access to Justice Act29 relating to the 
matters addressed in this Consent Decree. 
      21.   Severability.  The Parties agree that if any of the provisions of the Consent Decree shall 
be held unenforceable by any court of competent jurisdiction, such unenforceability shall not render 
unenforceable the entire Consent Decree, but rather the entire Consent Decree shall be construed as if not 
containing the particular unenforceable provision or provisions, and the rights and obligations of the 
Parties shall be construed and enforced accordingly. 
      22.   Invalidity.  In the event that this Consent Decree in its entirety is rendered invalid by any 
court of competent jurisdiction, it shall become null and void and may not be used in any manner in any 
legal proceeding. 
      23.   Subsequent Rule or Order.  The Parties agree that if any provision of the Consent 
Decree conflicts with any subsequent Rule or Order adopted by the Commission (except an Order 
specifically intended to revise the terms of this Consent Decree to which Gable does not expressly 
consent) that provision will be superseded by such Rule or Order. 
      24.   Successors and Assigns.  Gable agrees that the provisions of this Consent Decree shall 
be binding on its successors, assigns, and transferees. 
      25.   Final Settlement.  The Parties agree and acknowledge that this Consent Decree shall 
constitute a final settlement between the Parties with respect to the Investigation.    

                                                     
29 See 5 U.S.C.  504; 47 CFR  1.1501 1.1530. 

                                      7 
                        Federal Communications Commission           DA 18-1051 

      26.   Modifications.  This Consent Decree cannot be modified without the advance written 
consent of both Parties. 
      27.   Paragraph Headings.  The headings of the paragraphs in this Consent Decree are 
inserted for convenience only and are not intended to affect the meaning or interpretation of this Consent 
Decree. 
      28.   Authorized Representative.  Each Party represents and warrants to the other that it has 
full power and authority to enter into this Consent Decree.  Each person signing this Consent Decree on 
behalf of a Party hereby represents that he or she is fully authorized by the Party to execute this Consent 
Decree and to bind the Party to its terms and conditions. 
      29.   Counterparts.  This Consent Decree may be signed in counterpart (including 
electronically or by facsimile).  Each counterpart, when executed and delivered, shall be an original, and 
all of the counterparts together shall constitute one and the same fully executed instrument. 
 
 
 
 
________________________________ 
Christopher L. Killion 
Deputy Chief 
Enforcement Bureau 
 
 
________________________________ 
Date 
 
 
 
 
________________________________ 
Paul P. Gable 
President 
Gable Signs & Graphics, Inc. 
 
 
________________________________ 
Date 
 
                               


                                      8